I understand that the submission referred to from NPWS in 2012 was made to a sub-group of the COFORD Council called the COFORD Council Land Available Working Group. The purpose of the submission was to highlight to participants in the group the obligations under EU and national law when considering afforestation.
The paper usefully documented requirements in 2012. There was, and continues to be, ongoing engagement between the Department and the NPWS around environmental protection, especially in relation to requirements around the Habitats and Birds Directives and how to incorporate these into forestry licensing. The paper in itself did not provide new information to the Department.